Audacious Property Group Pty Ltd as trustee for The Promised Land Trust Trading as Audacious Buyers Agents ABN 44 715 203 250

1. Background

Thanks for visiting our Privacy Policy (Policy). We are Audacious Property Group Pty Ltd as trustee for the Promised Land Trust trading as Audacious Buyers Agents ABN 44 715 203 250 (referred to as Audacious Buyers Agents, we, our, us, and other similar terms). We are committed to providing quality services to you and this Policy outlines our ongoing obligations in respect of how we manage your Personal Information. It applies to our Buyer’s Agent Agreement and any other agreements or interactions we may have with you in the course of providing buyer’s agency services including, identifying suitable properties, conducting property evaluations and due diligence, providing auction bidding services, finalising paperwork, organising property inspections, negotiating real estate transactions or providing complete end-to-end property buying services on your behalf (Buyer’s Agency Services).

When we talk about Personal Information, we mean information or an opinion about an identifiable individual (not a company), whether or not that information or opinion is true or in a material form (Personal Information).

From 1 July 2026, we are a reporting entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and the rules, regulations and instruments made under it (AML/CTF Laws). When we provide our Buyer’s Agency Services we are required to verify the identity of our clients and, where relevant, of other parties to a transaction, to conduct customer due diligence and ongoing monitoring, to keep records and where necessary, to make reports to the Australian Transaction Reports and Analysis Centre (AUSTRAC). This affects the Personal Information we collect, use, disclose and retain, as described in this Policy.

2. Disclaimer

While your privacy is important to us, nothing in this Policy constitutes a voluntary opt-in to any privacy laws, anywhere in the world, which we are not statutorily bound to comply with.

3. Collection of Personal Information

3.1 How we collect Personal Information

We collect Personal Information in the ordinary course of our business, which is the provision of our Buyer’s Agency Services. Personal Information is collected when you:

• (a) engage us to provide Buyer’s Agency Services;
• (b) contact or correspond with us via email, telephone or via our website;
• (c) participate in property inspections, meetings or consultations;
• (d) subscribe to our newsletters or complete surveys or online forms;
• (e) use or enquire about our Buyer’s Agency Services; or
• (f) seek support in relation to our Buyer’s Agency Services.

Information will only be collected directly from you unless you authorise another person to provide the information such as your legal, financial, insurance or real estate representative.

However, we may also collect Personal Information from other parties, and through external service providers we engage, where this is reasonably necessary to verify your identity or to meet our obligations under the AML/CTF Laws. Where we do so, an external identity verification and compliance provider acting on our behalf may contact you directly to collect or verify information and documentation.

3.2 What Personal Information is collected?

The types of Personal Information we collect include your full name, address, telephone number, email, date of birth, identification documents such as your photo identification card/proof of age card, driver’s license or passport, financial details including your preferred budget and loan pre-approval information, property preferences and requirements, employment details, personal information of your family members or co-purchasers where relevant to the property search or transaction, your social media details when you engage with us on social media and any additional information you or your authorised representatives (such as your financial or legal advisor) provide to us in connection with our services.

To meet our obligations under the AML/CTF Laws, we (or the external providers we engage) may also collect and verify information needed to confirm your identity, including government-issued identification and the verification reference data associated with it, your source of funds and source of wealth, beneficial ownership and ownership-structure details, information about whether you are a politically exposed person, and the results of sanctions, politically exposed person and adverse media screening. Where relevant to a transaction, we may collect and verify this type of information about other parties to the transaction, such as vendors or sellers, and about related individuals such as beneficial owners and authorised representatives.

We only collect sensitive information where it is reasonably necessary for the purposes of providing our services. For example, you may provide us with health information to help us identify suitable properties with wheelchair accessibility features or personal information about your background or preferences where it relates to property location, such as proximity to religious or cultural facilities. We may also collect sensitive information, including information about whether you are a politically exposed person or information revealed through sanctions or adverse media screening, where the collection is reasonably necessary for, or is required or authorised by, our obligations under the AML/CTF Laws.

Where you contact us on behalf of your employer, the information you provide often contains information about your employment, position and employer’s contact details. In those circumstances certain employment information is collected.

If you do not provide the Personal Information we request, we may be unable to respond to your enquiry, provide our Buyer’s Agency Services, progress or complete a transaction or comply with our legal and regulatory obligations.

4. How we use Personal Information

4.1 Why we collect Personal Information

We collect your Personal Information for the primary purpose of providing our Buyer’s Agency Services to you. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure.

Examples of when we may use your Personal Information include:

• (a)informing you about our Buyer’s Agency Services;
• (b)providing you with our Buyer’s Agency Services including identifying, evaluating, negotiating for and/or purchasing suitable property on your behalf;
• (c)liaising with third parties on your behalf, including real estate agents, property sellers, brokers, legal representatives, property managers, lenders, mortgage brokers or other service providers;
• (d)administration needs in relation to providing you with our Buyer’s Agency Services, including record-keeping;
• (e)recording information at or accessing information from, government agencies, title registries or statutory bodies, where relevant to our Buyer’s Agency Services;
• (f)improving our services, website, marketing or customer experience;
• (g)dealing with requests, enquiries or complaints and other customer care related activities; and
• (h)carrying out any activity including verification of identity, in connection with a legal, governmental or regulatory requirement imposed on us or in connection with meeting our customer identification, customer due diligence, ongoing customer due diligence, transaction monitoring, sanctions and politically exposed person screening, record-keeping and reporting obligations under the AML/CTF Laws and other anti-money laundering and counter-terrorism financing obligations, legal proceedings, crime or fraud prevention, detection or prosecution.

4.2 Direct marketing

Where you provide us with consent to do so (e.g. if you have subscribed to our email lists or have indicated that you are interested in receiving information from us), we may send you marketing communications by email about our services that we feel may be of interest to you.

You can opt-out of such communications if you would prefer not to receive them in the future by using the “unsubscribe” facility provided in the communication itself.

4.3 Surveys or market research

We (or an appointed third party) may also conduct surveys or market research and may seek other information from you on a periodic basis. These surveys will provide us with information that allows improvement in the type, quality and the manner in which our services are offered to you. You can opt out of participating in such surveys or market research using the facilities made available to you.

5. Identity verification and anti-money laundering obligations

We are a reporting entity under the AML/CTF Laws. Before and during the provision of our Buyer’s Agency Services, we are required to identify and verify our clients and, where relevant, other parties to a transaction and related individuals such as beneficial owners and authorised representatives. We are also required to understand the nature and purpose of the transaction and, where applicable, your source of funds, and to carry out ongoing customer due diligence throughout our relationship with you. In some circumstances, for example, where a matter involves a politically exposed person or presents a higher money-laundering or terrorism-financing risk, we may be required to carry out enhanced customer due diligence.

We may engage external service providers to carry out customer identification, customer due diligence, identity verification, sanctions, politically exposed person and adverse media screening and related compliance functions on our behalf. These providers may collect Personal Information from you and from independent and government data sources, may contact you (or other parties to a transaction) directly to obtain or verify information and documentation, and may store that information and the associated verification and compliance records on our behalf.

If we are unable to verify your identity, or you do not provide the information that we (or our service providers) reasonably require to comply with applicable AML/CTF Laws, we may be unable to provide, or to continue to provide, our Buyer’s Agency Services to you, and we may be required to delay, suspend or decline a transaction.

In some circumstances the AML/CTF Laws and other laws require or permit us to collect, use, disclose and retain Personal Information without your consent, and may prohibit us from telling you that we have done so or that a report has been made to AUSTRAC or another authority. Where this is the case, we may be unable to inform you that your Personal Information has been collected, used or disclosed for these purposes, or to give you access to it.

As a reporting entity, we may be required to give reports to AUSTRAC, including suspicious matter reports and threshold transaction reports, and those reports may include Personal Information about you. We are prohibited by the AML/CTF Laws from telling you, or any other person, that such a report has been, or may be, made. Making a report of this kind does not breach any duty of privacy or confidentiality that we owe to you.

Where the providers we engage collect or store Personal Information or compliance records on our behalf, we take reasonable steps to ensure that the information is held securely and is handled in accordance with this Policy, the APPs and the AML/CTF Laws.

6.Cookies and browser analytics

6.1 What are cookies

Cookies are small text files that are placed on your computer by the websites you visit. They are processed and stored by your web browser. When you visit a website or engage with a business through social media, certain information is collected by cookies. This is generally anonymous information and it does not reveal your identity. In and of themselves, cookies are harmless and serve crucial functions. They are widely used in order to make websites work more efficiently and improve the user experience, as well as to provide information about the use of a website.

6.2 Why we use cookies

By storing and using information about your use of our website, including preferences and habits, we are able to make your visit to our website more productive. For example, some cookies remember your language or preferences so that you do not have to repeatedly make these choices.

6.3 We use the following types of cookies:

• (a)Required cookies. These are cookies that are required for the operation of our website. They include, for example, WordPress cookies that allow the implementation or change of website content in real-time and helps determine if your browser can display emojis properly.
• (b)Analytical cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are able to find what they are looking for easily. We also use third party cookies, such as those provided via the Google Analytics service. The information passed back to such third party providers is anonymous.
• (c)Marketing cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you and remember your preferences. These cookies also record your visit to our website, the pages you have visited and the links you have followed. We may use this information to make our website and communications sent to you more relevant to your interests.

6.4 How can I remove cookies

Your web browser can choose whether or not to accept cookies. Most web browser software is initially set up to accept them. If you do not want your browser to use cookies, you can manage and control their use through your browser, including removing cookies by deleting them from your “browser history” (cache) when you leave the site. However, if you choose to reject cookies some parts of our website may not work properly.

7. Data retention and security

7.1 Security mechanisms we employ

Generally, we store your Personal Information using secure systems designed to protect your information from unauthorised access, modification and disclosure. Personal Information is also stored on our staff’s computers or devices (such as emails from you or paperwork related to real estate transactions) and where necessary as hard copy files (such as printed invoices and documents related to property purchases or client onboarding).

Personal Information that we store or transmit is protected by technical security and access controls, including username and password authentication and data encryption (such as SSL) where appropriate. We also implement organisational security measures to protect Personal Information. These include limiting staff access to Personal Information to what is reasonably necessary to provide the Buyer’s Agency Services and maintaining confidentiality over Personal Information.

In the course of providing our Buyer’s Agency Services, we may engage third party service providers to support our business operations. We take care to work with service providers who we believe maintain an acceptable standard of data security compliance like GoDaddy and Microsoft.

7.2 How long we keep your Personal Information

We retain your Personal Information for as long as is necessary to provide our Buyer’s Agency Services to you, as required for our internal business operations, and to comply with our legal obligations.

If we hold Personal Information about you, and we do not need that information for any purpose, we will take reasonable steps to destroy or de-identify that information, in accordance with the Australian Privacy Principles (APPs), unless we are prevented from doing so by law.

Under Australian law, financial records, such as those relating to financial transactions, must be retained for 7 years after the transactions associated with those records are completed. We are also required under the AML/CTF Laws to keep records relating to customer identification, customer due diligence and our compliance activities, generally for at least 7 years after the end of our relationship with you or after the relevant transaction or activity. We, or the service providers we engage on our behalf, will retain those records for at least that period, even if you ask us to delete your Personal Information, as we are obligated to do so under law.

If you no longer want us to use your Personal Information, you can request that we erase it. Where possible we will do so in accordance with the APPs. However, where you request the erasure of your Personal Information we will retain information from deleted accounts as necessary for our legitimate business interests, to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations or requests by government, a court of law, or law enforcement authorities, enforce the terms of service and take other actions permitted by law. Any information we retain will be handled in accordance with this Policy. In particular, we cannot erase Personal Information that we are required to retain under the AML/CTF Laws or other laws, including customer identification, customer due diligence and compliance records.

8. Disclosure of your Personal Information

8.1 Who we share your Personal Information with?

Your Personal Information may be disclosed to:

• (a)real estate agents, property sellers, property buyers, developers or their representatives involved in real estate transactions relevant to you;
• (b)your authorised representatives, such as your legal or financial advisors;
• (c)mortgage brokers, financial institutions, insurance providers or other third party service providers involved in finalising a real estate transaction on your behalf, where you request or authorise us to do so;
• (d)our employees, a related company and our professional advisers (lawyers, accountants, financial advisers, etc.);
• (e)external service providers we engage to perform identity verification, customer due diligence, sanctions, politically exposed person and adverse media screening and other AML/CTF compliance functions on our behalf;
• (f)regulators and government authorities (including AUSTRAC) in connection with providing our Buyer’s Agency Services, our compliance procedures and fulfilling our legal obligations, including law enforcement agencies to assist in the investigation and prevention of criminal activities;
• (g)a third party, in order to enforce or defend our rights, or to address financial or reputational risks;
• (h)third party contractors, suppliers and service providers with whom we have a business association, including:
  • (i)administration service providers;
  • (ii)marketing service providers; and
  • (iii)information technology service providers.
• We will not disclose your Personal Information other than in accordance with this Policy without your consent.

9. Anonymity and use of pseudonyms

If you contact us with a general enquiry, we may interact with you anonymously or through the use of pseudonyms. However, you are required to provide true and accurate details when requesting the provision of our services. You agree you will provide accurate information if we require it. Especially because we are required to verify identity under the AML/CTF Laws, you cannot deal with us anonymously or by using a pseudonym where we are required to identify and verify you in order to provide our Buyer’s Agency Services or to meet our obligations under the AML/CTF Laws.

10. Access to Personal Information and corrections

We endeavour to only hold Personal Information that is accurate, complete and up-to-date. You have the right to make a request to access Personal Information which we hold about you and to request corrections of any errors in that data. To make an access or correction request, contact us using the contact details provided at the end of this Policy. There are some circumstances in which we may not be able to give you access to, or correct, your Personal Information. For example, where doing so would be unlawful, would prejudice an investigation, or where access or correction is restricted by the AML/CTF Laws or other laws. If we refuse access or correction, we will tell you why, except where we are not permitted by law to do so.

In order to protect your Personal Information, when you contact us, we may require identification from you before releasing the requested information or making the correction.

11. Communications and privacy concerns

Your privacy is important to us. If you have any complaints, concerns or questions about our handling of your Personal Information, we ask that you first contact our privacy officer whose contact details are listed below. We will investigate your complaint and reply to you in writing if you provide us with contact details and request us to do so.

1. Email: james.wong@audaciousbuyersagents.com.au
2. Telephone: 0413 690 498
3. Post: 6 Nullarbor Circuit Forest Lake, QLD 4078
4. Online: https://audaciousbuyersagents.com.au/
5. If, after we have conducted our investigations, you are still not satisfied, then we ask you to consult with the Office of the Australian Information Commissioner:
6. Email: enquiries@oaic.gov.au
7. Telephone: 1300 363 992 (from overseas +61 2 9284 9749)
8. Post: GPO Box 5218 Sydney NSW 2001

12.Variations to this Policy

We will need to change this Policy from time to time in order to make sure it stays up to date with the latest legal requirements and any changes to our privacy management practices.

When we do change the Policy, we’ll make sure to notify you about such changes, where required. A copy of the latest version of this Policy will always be available on this page.

This Policy was last updated on 19 June 2026.